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Speech to the Major Projects Association, London, 12 May 2011

Judith Hackitt CBE, HSE Chair

The Challenges of delivering renewable energy projects

Policy and Strategy for Safety

First of all, may I thank the Major Projects Association for having the foresight to invite me to speak to you today on the health and safety challenges associated with new and emerging energy technologies including renewables.

It is also very significant, I think, that I am speaking to you relatively early in the course of the day because that is very symbolic. That is exactly when the health and safety issues associated with any new technology or major project should be addressed – up front, in the formative stages of planning the project – not as an afterthought or an add on when all of the designs are complete and construction is just about to start.

It was in that spirit of trying to be proactive and ahead of the game that the Health and Safety Executive, some two-and-a-half years ago, established a small expert group to look at health and safety regulation of new and emerging energy technologies. The group has now completed its work and reported back to the Board of HSE late last year.

In my remarks this morning I would like to set out some of the principles that lie at the heart of the approach that we have taken and also share with you some of the key findings and recommendations which are in the report. My focus will be predominantly on offshore wind generation which is where I know you will be focusing in your later discussions but I also want to set that in the broader context of the range of challenges and hazards we will need to face and address in moving the UK to a low carbon energy economy over the coming decades.

Just as the role of the Major Projects Association is to improve the delivery of major projects through the sharing of experience, knowledge and ideas, so we in HSE have addressed the challenges of new and emerging energy technologies by building upon our many years of experience of regulating existing energy technologies and other major hazard industries both on and off shore.

I want to be clear from the outset that our role does not involve recommending or stating a preference for any one technology over another – whether we are talking about new nuclear power generation, carbon capture and storage, wind or wave technologies our role is to be impartial and independent; to identify the hazards, consider how they might best be regulated by us and managed by those who create the risks in order to assess the safety of each technology. Our role is one of enabling any/all of the technologies to be adopted successfully taking account of potential risks to those who will build, operate and maintain the facilities and any risks to the general public which may arise as a result of these activities.

In setting up our emerging energy technologies group we wanted to ensure that potential hazards and risks are identified and considered as early as possible in the development processes. One of the most important lessons we should all have learned from the past is that inherently safe design is far better and more cost effective in the long run than attempting to “bolt-on” safety measures at a later stage in the process or worse still after lessons have been learned because someone has already been harmed.

The exact nature of our energy landscape in the future is uncertain and will depend on many factors – of which safety is one, but clearly not the only one. So we have tried to develop an approach that looks at the full breadth of the landscape and anticipates what we might face in any scenario. I don't intend to say anything in detail about new nuclear today, but you will of course be aware that in the wake of events in Japan in March that there is further work ongoing to consider what this might mean for the UK and new nuclear build. Mike Weightman – Chief inspector of the Office of Nuclear Regulation – the newly created agency under HSE's umbrella – will present his interim report to Government later this month and his full report in the Autumn.

We can though be confident that the UK's energy generation in the future will contain a more diverse mix of technologies than in the past – a less centralised and more diverse system which includes existing and new technologies, harnessed in an unprecedented variety of ways.

We have reviewed our own knowledge bank and we have concluded that we are well placed to extend our current range of activities to embrace the full assortment of emerging energy technologies relevant to the UK. Ultimately however, the level of health and safety achieved in the sphere of emerging energy technologies will be determined by how well those creating the hazards and risks – the dutyholders as we call them, that means many of you in this room – manage and control them as it is their legal duty to do so.

But we can't leave that to chance. Part of our role is to help that process and all parties involved in developing and deploying the new technologies to foresee those hazards, recognise the risks and implement appropriate management and control measures. This in turn then enables us to play an important role in providing public reassurance that these risks are being properly managed and controlled.

This is an important responsibility which we take seriously. Building public confidence in new technologies is important to us all and we know we play a significant role in that.

New and emerging technologies bring with them specific and generic risk factors.

Some of the generic factors include:

The rapid expansion that is expected to take place will mean increased activity levels which de facto generates a sharp increase in the potential for health and safety-related incidents and accidents;

The speed of expansion required may also create a major skills gap that is difficult to fill quickly, which may have the consequence of increasing the number of inexperienced people employed. We know and have good evidence to demonstrate that new and inexperienced recruits are the most vulnerable in any industry sector this one will be no exception;

New companies may struggle to establish their own appropriate health and safety culture quickly;

Existing companies may find themselves faced with new and unfamiliar hazardous activities;

Embedded power projects will create unfamiliar energy-related risks on sites such as schools, hospitals and farms – unusual locations for energy risks;

The potential for delays and economic uncertainty may impact on the schedule for the implementation of new technologies with the effect that extensions are sought to the original working life of many existing facilities we already know some of the challenges this creates from the offshore oil and gas industry; and

All parts of the industry will face working under severe time pressures, in unfamiliar environments, with multiple contractors and contractor interfaces.

But all of these should be seen as challenges which need to be addressed and which we can overcome. The danger lies in not recognising that they exist and in not looking as broadly as possible to learn lessons in how to overcome these issues.

Consider for one moment the challenges which were put in front of the ODA and its partners back in 2007; to regenerate large tranches of land in the east end of London and build an Olympic park in time for the 2012 Olympics. A project of enormous scale involving thousands of diverse groups of contractors all working under very clear time pressures and yet the safety performance of the Olympics 2012 team has been a shining example that everyone should seek to learn something from.

So let's now focus on some of the hazards identified in HSE's recently published report on emerging energy technologies

Major health and safety hazards are defined as those which have the potential to cause multiple fatalities and serious injuries and/or widespread damage to property and the environment from a single incident. We have identified a number of potential major hazards associated with new and emerging energy technologies with a few summarised in this table (A more extensive table of all hazards identified can be found in the report which I'd urge you to read - its URL is at the bottom of this slide).

In the case of offshore renewable you will see that the potential for major accident hazard is associated with the possibility of collapse of working platforms during turbine or substation construction.

We must remember that in addition to major hazards there is the potential for new technologies to present lower level health hazards. These need to be addressed effectively not least in making the workforce aware of the hazards to long term health as well as the more immediate and obvious workplace safety hazards.

Here again in the case of wind power in particular, whether destined for on or offshore, a wide range of hazardous chemicals and solvents can be used during manufacture of turbines including epoxy resins and styrene.

Safety hazards will include the potential for falls, electrocution and entrapment during construction and maintenance. Significant lifting hazards associated with dockside assembly and loading of offshore turbine equipment onto ships and potentially even more challenging, the use of lift vessels and ships crews in unfamiliar and unpredictable conditions in the North Sea.

Some of the hazards to the public which we have identified will appear in the list of major hazards. Others, however, are likely to be more localised. Our list of identified hazards in this area does not include anything specific to offshore wind but you will note that onshore wind generation does carry the potential for impact on the public from blade throw or turbine collapse if/when they are located close to communities. I've also included some other issues that could, on face value, appear innocuous but might benefit from further thought by those of you in the field to ensure they are dealt with sensibly.

Having taken you through the process we have engaged in I can now share with you some of our conclusions which I hope you will find encouraging. These are:

It is our intention to promote sensible and proportionate management and control of hazards and risks which means regulating new technologies to the same standards as existing industries with comparable hazard and risk profiles at all stages in the process – design and construction as well as operation, but also seeking to simplify the framework wherever possible;

Our starting point is an assumption that further regulation will not be required unless evidence emerges which makes it obvious that the current framework does not meet requirements; and

We are confident that the general provisions of the existing HSWA can form the basis of a fit for purpose regulatory framework for both on and offshore emerging energy regimes. But we will be keeping a close eye on developments and in particular on industry's ability and commitment to control and manage the hazards for themselves. In other words we are looking for evidence of industry leadership.

The initial signs are encouraging. We have seen some strong evidence of leadership from Energy generating companies who want to set standards themselves from the outset. They want to be able to demonstrate safety throughout their whole supply chain not just in their own company. This is a laudable approach and one that we want to encourage.

We recognise that cooperating and collaborating efficiently, not only with employers but also with other relevant organisations will be essential to ensuring that an appropriate health and safety culture is built and maintained in all of the various fields of emerging energy technologies.

To foster this approach we will:

Share our assessments of potential hazards widely;

Encourage duty holders to take ownership in addressing health and safety considerations at an early stage in every project's life;

Engage with trade bodies, sector skills providers and trades unions encouraging them to take the lead in setting standards and generating industry/sector specific guidance;

work closely with other Government departments to ensure consistency of approach and joined up thinking;

encourage the provision of tailored advice for small businesses where and when they are involved;

encourage the broadest range of cross sector learning and good practice sharing; and

endeavour to exert influence to ensure that research and development takes account of health and safety risks at the earliest possible stage and designs them out where possible.

Our intent and our mission is to act as the champion for health and safety in every industry sector and the emerging energy technologies are no exception to this. We are ready and willing to play our part in helping the UK build and develop its competences to secure a new energy landscape for the future which is at least as safe and healthy for the workforce and the public as that which we know and manage today.